ML20140B487

Forwards Bracketed Version of 960812 Investigation Rept W/Request to Be Withheld from Public Disclosure in Accordance w/10CFR2.790(a)(6). Also Encl, Affidavit Supporting Request

ML20140B487
Person / Time
Site:	Limerick
Issue date:	05/08/1997
From:	Walter MacFarland PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	Miller H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
Shared Package
ML20140B460	List: ML20140B455 ML20140B487
References
NUDOCS 9706060230
Download: ML20140B487 (16)

Text

__. _._ __..__________..____..___m_.___.. ___.m.. .. _ _ . .

',f Wiltsr G. MecFerland,lV, P.E.

, Vice President .

.y . [

Umerick Generatrig Station

.. - y .

t PECO NUCLEAR e= =vc-ev PO Box 2300 t A (JNir or PECO Entscy Sanatoga. rA 19464 0920 l 4

610 718 3000 t Fax 610 718 3008  !

Pager 1800 672 2285 #8320 May 8,1997  ;

Docket Nos. 50-352 I 4 50-353 i

License Nos. NPF-39 I I NPF-85 '

- Mr. Hubert J. Miller, Administrator, Region I i

U.S. Nuclear Regulatory Commission l 475 Allendale Road .

3; King of Prussia, PA 19484 )

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SUBJECT:

Limerick Generating Station - Units 1 and 2 l Request for Withholding of an Investigation Report j l

Dear Mr. Miller:

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l. By letter' dated November 13,1996, PECO Energy provided the NRC with a copy  !

of an internal investigation report that addressed alleged instances of record '

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falsification at Limerick Generating Station. The letter and its attached affidavit

requested that the report be withheld from public disclosure in accordance with -  ;

the provisions of 10CFR2.790. By letter dated April 10,1997, the NRC j i responded to the request by determining that only certain information could be t i- withheld from public disclosure, and that there was insufficient bases for l l withholding the entire report. As a result, the NRC requested that PECO Energy 1 i forward a version of the investigation report within 60 days that has " bracketed" -!

i the specific information sought to be withheld. We understand that the NRC ,

j intends to place a redacted version of the report in the Public Document Room.

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Accordingly, enclosed is a bracketed version of the investigation report. The

bracketed information is considered confidential information, the disclosure of

! which would constitute an' unwarranted invasion of the personal privacy of the individuals involved. The confidential information is being submitted to the Commission with a request that it be withheld from public disclosure in accordance with Section 2.790(a)(6) of the Commission's Regulations. Attached

. is an affidavit setting forth the reasons in support of this request to withhold from public disc!osure.

If you have any additional questions, please contact us.

Very truly yours, 6LcJUdhd ~

Attachment -  !

Enclosure i 9706060230 970529 F5 PDR ADOCK 05000352 ti 0- PDR $ )

,a COMMONWEALTH OF PENNSYLVANIA .

. ss.

COUNTY OF MONTGOMERY Walter G. MacFarland, IV, being first duly sworn, deposes and states as follows:

1. I am Vice President, Limerick Generating Station of PECO Energy Company, licensee under Facility Operating Licenses NPF-39 and NPF-85, and I am l duly authorized to execute this affidavit. I

2. The information requested by the NRC includes detailed information i concerning an allegation of wrongdoing, identifies or could be used to  !

identify the individuals involved in the allegation, and identifies or could be  ;

used to identify the individuals involved in the investigation of the allegation.

I am familiar with the contents of the investigation report.

3. The information contained in the investigation report is of the type customarily held in confidence by PECO Energy Company and is not i customarily disclosed to the public. The information has not been disclosed )

to the public and is not available from public sources. PECO Energy Company has limited the distribution of the information in the report to those  !

individuals with a need to know to fulfill their legal and management i responsibilities.  !

4. The bracketed information should be withheld from public disclosure by the l NRC because such disclosure is not required in the public interest and such disclosure would constitute an unwarranted invasion of the personal privacy of not only the individuals directly involved in the investigation, but also those individuals who provided information or were identified in the course of the investigation.

5. Based upon the foregoing, PECO Energy Company has concluded that I i

disclosure of the bracketed information contained in the investigation report would constitute an unwarranted invasion of the personal privacy of the individuals involved, would adversely affect the interests of the individuals l involved and the interests of PECO Energy Company, and that such '

disclosure is not required in the public interest.  !

( d a a % L\~

Walter G. MacFarland, IV Vice President - LGS Subscribed and sworn to before me this ## day of May,1997.

v/ dtm * /

NotaryFublic Notarial Seal Sharon J. Adarns. Notary Public M n xprk u 1,1998 Mermer, Penrsykansa Assocaban of Nolanos

1 PECO Energy Company Memorandum Location: Security, S9-1 1

l Date: September 30,1996 To: T. J. Niessen, Jr., Director Nuclear Quality Assurance i

From: J. C. Rullo, Manager-Security i

Subject:

Security investigation-Quality Concem 127 j Allegation of Falsification of Fire Protection Section i

Surveillance Test, Limerick Generating Station On August 12,1996 an investigation was initiated at the request of Limerick a

Generating Station (LGS) manager 6ent related to a Quality Concem alleging an employee of the LGS Fire Protection Section may have failed to property i perform a Surveillance Test.

] On August 7,1996 an allegation was received by management from an

! individual indicating the employee was not in the LGS plant a sufficient amount of time to perform the inspections necessary for Surveillance Test ST-7-022-l 951-0, titled: Fire Hose Station Visual Inspection, dated July 29,1996.

A subsequent joint investigation involving the Security Division and the LGS Quality Division revealed the allegation to be correct and identified and

confirmed additional falsifications of Surveillance Tests by the individual. The

) scope of the investigation also identified other unrelated irregularities involving l Fire Protection Surveillance Tests by a and a f

A listing of the Surveillance Tests reviewed by the Odity Division and the specific areas of concem identified is attached.

l The following reflects the specific information related to each individual identified

through the course of the investigation

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Security investigation - Quality Concern 127

i. September 30,1996 l

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i l l was alleged to have failed to properly conduct Surveillance Test

ST-7-022-951-0, titled: Fire Hose Station Visual inspection, for which he signed l indicating he satisfactorily performed on July 29,1996. Specifically, was l

} believed to have not been in the LGS plant long enough to mnduct the  ;

i Surveillance Test. l l

j A preliminary investigation by Site Management determined had not l 4'

entered the certain areas of the LGS Plant or,' July 29,1996 necessary to j complete the Surveillance Test as require (1 was interviewed on August 13,1996 and provided a written statement admitting he had annotated by signing his initials on the Surveillance Test in question, affirming on July 29,1996 he visually observed the Fire Stations at all j the LGS Plant locations as required by the Surveillance Test. During the course '

of the interview, admitted to not going to all the listed locations on the Surveillance Test on that date. provided information he annotated the

' inspections as completed on July 29,1996, but that he had taken credit for I previous observations he made on previous dates of the fire hose stations.

Management was advised of the interview results and on August 13,1996, was suspended from employment and his unescorted access was suspended pending the results of the investigation.

Further investigation revealed irregularities in four previous Surveillance Tests .

conducted by - i. failed to enter specific areas of the LGS Plant l

necessary to complete ST-7-022-951-0, titled: Fire Hose Station Visual  ;

inspection, for which he signed, indicating he satisfactorily performed on  ;

April 3,1995, June 8,1995, April 30,1996 and May 29,1996.  !

was again interviewed on August 16,1996 and provided a written ,

statement admitting to not completing the four Surveillance Tests properly in that I he was not in the areas required to observe the fire hose stations on the dates in question. admitted to signing the Surveillance Tests as performing them on the dates in question.

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i Security investigation - Quality Concern 127  !

{ September 30,1996 j

Page 3 {

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. in the interview of August 16,1996, provided a written statement

, regarding concems he noted in the Fire Protection Group which he had surfaced j i

' previously to his coworkers, manager and diredor. As part of the investigation,  ;

the issues were reviewed and investigated by the Quality Division. Attached are - i

. the results of the Quality Division investigation.

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Further investigation revealed an irregularity in an additional Surveillance Test  ;

i, conducted by a. failed to enter a specific area of the LGS Plant

[ necessary to complete ST-7-022-950 0, titled: Fire Suppression Water System j j

(FSWS) Spray and Sprinkler Visual inspedion, for which he signed indicating he i i satisfactorily performed on June 28,1995. This matter was not pursued with j l anotherinterview of as he had previously indicated other Surveillance i j

Tests he performed may not have been completed properly.

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l. On September 11,1996 management terminated employment.

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1 j The investigation revealed an irregularity in the portion of an Surveillance Test i' conducted by . failed to enter specific areas of the LGS Plant necessary to complete ST-7-022-952-0, titled: Fire Hose Station Refuel inspedion, dated: 8/23/95. The Surveillance Test reflects a signature by i

indicating permission to start the test occurred on August 22,1995 at 0930

! hours. again signed the Surveillance Test indicating he completed  !

l satisfactorily and performed on August 23,1995 the portions of the Surveillance 1

Test he initialed. Records indicate _ was not in the required areas to j perform the Surveillance Test on either of those dates.

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[;. was interviewed on August 20,1996 and provided a written statement 1

admitting to not being in the areas necessary to perform the requirements of the i Surveillance Test on the dates he annotated on the Surveillance Test.

- offered two possible explanations for why he signed and dated the Surveillance l

Test as: he took credit for the inspections done that date by a coworker; or, he took credit for the fire hoses being recently replaced but did not visually inspect I

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them on the dates he annotated on the Surveillance Test.

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i Security investigation - Quality Concern 127

, September 30,1996 '

i Page 4 f r Man'agement was advised of the 'witerview results and suspended unescorted access pending completion of the investigation.  !

Further investigation determined the coworker named by as having i actually done the inspections had, in fact,'not done the inspections. Also, the i hose replacement he indicated he could have taken credit for occurred after, not '  !

before, the Surveillance Test was performed and included no hoses in the areas 1 in question. .

i. .

contacted his management on August 21,1996 and related he performed l the Surveillance Test on a previous date, approximately one week earlier, but  ;

i had annotated the wrong date on the Surveillance Test. i l

j An investigation of the records indicates was in the necessary areas of j  :

the LGS Plant to perform the Surveillance Test properly on August 19,1995.

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t Management reinstated  : unescorted access on September 4,1996 i pending a final determination.

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The investigation revealed an irregularity in the portion of an Surveillanoe Test conducted by l was found not to have been in an area of the  !

LGS Plant a sufficient amount of time necessary to complete a portion of ST 022-952 0, titled: Fire Hose Station Refuel inspection, for which - signed indicating he satisfactorily performed on August 23,1995.-

was interviewed on August 21,1996 and provided a statement he does not recall the events of August 23,1995, but believes he either did the inspection but rushed through it; was called away during the inspection to another matter; or took credit for someone else who may have told him they did the inspection. ,

Management was advised of the interview results and suspended unescorted access on August 21,1996 pending completion of the investigation.

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!* Security investigation - Quality Concem 127 i September 30,1996 s Page5 The investigation of records indicated - was in the area of the i

questionable test for no longer then one minute and fdty-nine seconds A i

functional test performed as part of the investigation concluded a minimum of

! three minutes and eleven seconds was necessary to perform the test, and one

{ minute and forty-five seconds to travel between the doors used as entrance and

, exit by on the date in question. Further investigation showed j was not assisted by anyone on the date in question.

4 l Management reinstated ' >

unescorted access on September 4,1996 j

pending a final determination by his employer.

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! Attachments 1

cc: J. W. Durham 4 W. G. MacFarland, IV J

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Bas:d on a review of PIMS, th:re w:re 119 Fire Protection Group Surveillance Tests identified as being performed between 1/1/95 and 8/12/96. Of there,48 were Fire Hydrant inspections, Fire Brigade Drills, Fire Pump & Back-up Fire Pump Operability tests and were not considered for review. Of the remaining 71 tests, 51 (71.8%) were selected for review based on equipment location and personnel access within the power block.

This review was conducted by comparing the surveillance test's signoffs and security card reader zone traces for test performem and associated IVORs to ensure that the individuals were actually in the equipment area for a reasonable aTiount of time required to perform the function. ,

4 Satisfactory at the Result for each test means that the identified personnel were in the appropriate areas for a reasonable length of time to adequately perform the task. 1 Date Surveillance Test Title Completed ST-7-022-951-0 Rev.10 Fire Hose VisualInspection 1-27-95 Result; satisfactory ST-7-022-951-0 Rev.10 Fire Hose Visual Inspection 2-28-95 Result; satisfactory ST-7-022-951-0 Rev.10 Fire Hose VisualInspection 4-3-95 Result: no evidence of entry to the refuel floor ST-7-022-951-0 Rev.10 Fire Hose Visual Inspection 5-8-95 Result satisfactory i

ST-7-022-951-0 Rev.10 Fire Hose Visual inspection 6-8-95 4 Result: no evidence of entry to A8-304 (Fan Room)

& A8-254 (Cable Spread Room) i ST-7-022-951-0 Rev.10 Fire Hose VisualInspection 7/5-6/95 Result: satisfactory I ST-7-022-951-0 Rev.10 Fire Hose Msual Inspection 8/4/95 Result satisfactory i ST-7-022-951-0 Rev.10 Fire Hr,se Visual Inspection 9/5/95 Result; satisfactory ST-7-022-951-0 Rev.10 Fire Hose Visual Inspection 10/6/95 Result: satisfactory ST-7-022-951-0 Rev.10 Fire Hose Visual Inspection 11/6/95 Result; satisfactory ST-7-022-951-0 Rev.10 Fire Hose Visual Inspection 12/5/95 Result satisfactory ST-7-022-951-0 Rev.10 Fire Hose Visual inspection 1/3/96 Result: satisfactory ST-7-022-951-0 Rev.10 Fire Hose Visual inspection 2/1/96 Result: satisfactory

Date j Surveillance Test Titta Completed ST-7-022-951-0 Rev.10 Fire Hose Visual Inspection 3/1/96 Result satisfactory .

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ST-7-022-951-0 Rev.10 Fire Hose Visual Inspection 4/1/96 Result; satisfactory ST-7-022-951-0 Rev.10 Fire Hose VisualInspection 4/30/96

, Result 1) no evidence of entry to A8-200/180  :

2) no evidence of entry into Unit 1 Rx. Encl.

although he accessed the refuel floor l

f ST-7-022-951-0 Rev.10 Fire Hose Visual inspection 5/29/96 3

Result: 1) completed refuel inspection in 2 mins. (8 hose stations)

2) completed Unit 1 Rx. Enct in 3 mins. (29 hose stations) <

ST-7-022-951-0 Rev.10 Fire Hose Visual inspection 6/27/96

Result satisfactory 1

[ ST-7-022-952-0 Rev.6 Fire Hose Station Refuelinspection 8/23/95 l Result individual was not in the area (A8-201/180) for a  ;

reasonable amount of time to perform a hose j inspection ST-7-022-953-0 Rev.6 Hose Cart Visual Inspection 1/9/95 Result

satisfactory ST-7-022-953-0 Rev.6 Hose Cart Visual Inspection 2/9/95 Result: satisfactory ST-7-022-953-0 Rev.6 Hose Cart Visual Inspection 4/13/95 Result: satisfactory ST-7-022-953-0 Rev.6 Hose Cart VisualInspection 5/16/95 Result: satisfactory i

ST-7-022-953-0 Rev.6 Hose Cart Visual Inspection 7/20/95 Result: satisfactory ST-7-022-953-0 Rev.6 Hose Cart Visual Inspection 8/18/95 Result: catisfactory ST-7-022-953-0 Rev.6 Hose Cart Visual Inspection 9/18/95 Result; satisfactory ST-7-022-953-0 Rev.6 Hose Cart Visual Inspection 4/16/96 Result satisfactory ST-7-022-953-0 Rev.6 Hose Cart VisualInspection 5/15/96 i Result: satisfactory ST-7-022-353-0 Rev.4 Halon System Inventory 3/5/96 Result satisfactory

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- Surveillance Ter:t Title C7mpleted i ST-7-022-353-0 Rev.4 Halon System Inventory 7/31/95 i

Result

satisfactory j 1

ST-7-022-353-1 Rev.4 Halon System Inventory 7/15/96

, Result: satisfactory (IVOR personnelinitials are not identifiable)  !

ST-7-022-353-1 Rev.3 Ha!on System inventory 3/5/96 j Result satisfactory ' j i

ST-7-022-353-1 Rev.3 Halon System inventory 7/31/95

Result: satisfactory y

j ST-7-022-353-2 Rev.4 Halon System Inventory 3/2/96 j Result: satisfactory i ST-7-022-353-2 Rev.4 Halon System Inventory 2/4/96 Result: satisfactory ST-7-022-353-2 Rev.4 Halon System Inventory 3/7/96 Result; satisfactory l ST-7-022-353-2 Rev.4 Halon System inventory 7/31/95 j Result: satisfactory

ST-7-022-950-0 Rev.4 Fire Suppression Water System 6/28/95

(FSWS) Spray and Sprinkler Visual i- Inspection j Result: no evidence of access to rooms 449,450,619 1 l (cable spread room or fan room) l l

ST-7-022-950-1 Rev.0 Fire Suppression Water System 6/9/95 l

2 (FSWS) Spray and Sprinkler Visual

! Inspection

! Result: satisfactory i ST-7-022-950-2 Rev.1 Fire Suppression Water System 11/2/95 (FSWS) Spray and Sprinkler Visual

Inspection

) Result: satisfactory ST-7-022-921-1 Rev.3 Fire Damper Inspection 2/26/96 i Result: satisfactory  !

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D:te Surveillance Test Title Completed ST-7-022-921-0 Rev.4 Fire Damper inspection 8/7/96 Result: satisfactory Work Process / Implementation:

damper 017-001on page 9, IVOR step was not signed off as being performed during walkdown of FPDs in A8-239; identified incorrect room numbers listed on COL and no identification labeling on the FPD to ensure accurate identification (all are identified with black marker)

ST-7-022-921-2 Rev.0 Fire Damper inspection 2/8/95 Result satisfactory ST-7-022-323-2 Rev.4 Halon System Operability 1/29/95 Verification Result satisfactory ST-7-022-323-1 Rev.3 Halon System Operability 2/7/96 Verification Result; satisfactory Work Process / implementation; The same person signed off as the Test Performer and the Management Reviewer ST-7-022-323-0 Rev.5 Halon System Operability 2/7/96 Verification Result: satisfactory Work Process / Implementation:

The same person signed off as the Test Performer and the Management Reviewer ST-7-022-250-0 Rev.3 FSWS Flow Test 6/12/95 Result: satisfactory RT-7-022-730-2 Rev.3 BOP FSWS Air / Water Nozzle 2/16/95 Flow Test Result satisfactory ST-7-022-730-0 Rev.3 FSWS Air / Water Nozzle Flow Test 8/29/95 Result: satisfactory Work Process / Implementation:

Suggest performing a step by step review and verification of the above three tests to ensure accuracy (i.e., panet/ valve / room numbers and locations) and adequacy.

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Surveillance Test Title Completed i

ST-7-022-922-2 Rev.4 Fire Rated Penetration Test Sample 2/2/95  !

VisualInspection l Result: satisfactory .

ST-7-022-922-0 Rev.5 Fire Rated Penetration Test Sample 2/27/96 VisualInspection ,

Result: satisfactory .

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General work process / implementation note:

Based on the ST reviews and zone trace comparisons, the majority of IVOR's required were performed by  ;

personnel entering and exiting an area / room at the same time as the performer. This raises a c,uestioi; on the integrity of the true independencq of the IVOR performance. An Independent Verification (IV) is verifiest.on by .

a second qualified individual operating independently after the activity to verify that a specific condition exists. .

-(See the Operations Manual Chapter OM-C-11.1 for IV guidelines and methods or reference A-C-33).

Reinforcement of Management expectations on performance of IVORs should be communicated to all Fire

. Protection Group personnel to ensure conformance or pursue appropriateness of revising tests to Double l Verifications (DV).

L Rev.4 (9/9/96)

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. Evaluation & Review of the following concerns was performed by:

Concern #1 - Fire System impairments (FSI) are in the reviewed stage not taken to complete. Also were they properly compensated?

Review Results - 23 of the 89 Fire System impairments (FSis) identified in March 1996 by IRM personnel were reviewed to determine if the required compensatory actions were taken. The FSIs found in the "REVWD" status can be placed into one of the following three categories: 1) Preventive maintenance activities deactivated and not performed 2)

More than one work order activity required the same component removed from service at the same time and the duplicate FSI was not used 3) FSI implemented by Site Management and not taken to "INPROG" status.

The preventive maintenance activities that are in the "DEACT" status are activities that have been removed from the PM program. The work described in these work orders have not been performed and no impairment of a fire system was made.

In several cases multiple activities of the same work order would impair the same fire protection feature. A review of the completion remarks for the work order and a review of other FSis created under that work order showed that shift management had reviewed the release of the fire protection feature and compensatory measures were in place. In all cases reviewed, a properly filled out FSI in the "COMPLT" status could be found in PIMS.  ;

A report of FSis in the "REVWD" status was obtained from maintenance planning. The report contained the shift supervision PIMS sign-offs when performed. A review of the report identified 22 FSis in the "REVWD" status in which at least the shift supervision sign i off was completed. Some of these FSis had all initial locations completed indicating that ,

the impairment had occurred and the system was retumed to service without placing the  !

FSI in the proper status. When the FSI is left in the "REVWD" status shift supervision would not review the impairment when determining compensatory actions for new impairments. Since this could lead to the improper compensatory actions being prescribed, the IRM generated PEP 10006009 to capture the issue.

The current FSI program provides the individual completing the work order activity with a j message to close the FSI and requires that the enter key be pressed a second time. AG-CG-12.1 provides direction to the implementing organization to status the FSI as complete i when the fire protection feature is retumed to an operable status. The issue of timely FSI l closure has been identified as a watch area in the Industrial Risk Management group self assessment.

Conclusion - Fire System impairments (FSI) were identified to be in the reviewed stage and not taken to complete. In our opinion this condition has no safety significance.

Computer programming enhancements should be made to assure FSis are taken to the INPROG status prior to being worked and to assure FSis are closed out when jobs are completed. Based upon PIMs review FSis were identified to have been properly compensated.

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. Concern #2 - Not all sections of fire rated assemblies were being inspected such as carpeted areas or areas blocked by installed plant equipment.

Review Results - The TRM surveillance requirements section 4.7.7.1 (a) states that the l

exposed surfaces of each fire rated assembly shall be verified operable by performing a' visual . inspection once per 24 months. ST-7-022-920-0 is utilized to perform the visual inspection of the fire rated assemblies as required by the TRM. On August 22,1996 IRM individuals familiar with the performance of the inspection were asked to describe their visual inspection technique. The test is performed by inspecting the visible sections of the fire rated assembly from the floor using flashlights and binoculars. Any permanent plant equipment, including carpeting, in the way of inspecting that section of the barrier are not removed for the inspection. Fire protection personnel from two plants in region I were contacted to discuss how they handle similar inspections. The LGS method of performing the inspection is consistent with other plants and is deemed to provide assurance that the barrier is intact.

The May 16,1996 performance of ST-7-022-920-1 was performed for 'structural walls but section 6.2.3 inspection of fire rated raceways was not performed The reason for not performing this section was that thermo-lag fire barriers were declared inoperable and compensatory actions were in place. The performance of this procedure should have been listed as a partial per A-3, " Temporary changes to approved procedures and partial procedure use". The use of this process ensures that only partial credit is given for.the performed section of the procedures and the appropriate partial work order generated to track the completion of the procedure.

Conclusion - Fire rated assemblies that are not " exposed" are not required to be inspected.

Concern #3 - ST-7-022-730-1 (FSWS Air / Water Nozzle Flow Test) if performed as written it will dump the system.

Review Results - ST-7-022-730-1 has been written to satisfy the surveillance requirements of TRM 4.7.6.2 (d) to perform an air flow test which would verify that each sprinkler header system or open spray nozzle is unobstructed. There were two types of systems tested by ST-7-022-730-1 preaction systems which incorporate the use of closed sprinkler heads and the integrity of the piping is supervised using air pressure. the air is supplied from the plant air system through a regulator. When testing this type of system the high/ low air pressure alarm is tested for both the high and low alarm points. The high pressure alarm is obtained by raising the system air pressure to a nominal 80 psig and verifying the alarm on the local release control panel. Low air pressure is then verified by opening the inspectors test valve to bleed off air pressure to the low alarm point while verifying airflow through the sprinkler header. This type inspection would verify that a flow path existed from the preaction valve to the inspectors test connection.

The other type of system tested are deluge water spray systems that incorporate the use of open spray nozzles. Two types of deluge valves are used in the design of the systems i at LGS. Smaller systems used small hydraulically operated deluge valves that use fire l system pressure to maintain the valve in the closed position. When testing these systems j i

the outer block valves for the systems are closed and the alarm pressure switch is isolated from these systems These actions would prevent the system from performing its design function. There are no plant impact statements in the test to warn shift supervision of the

ch;nge in st:tus of the syst:m or ensura that compensitory tctions era m:intrined. Th3

, IRM has initiated 1006033 to investigate plant impact of fire system tests.

1. Airflow is established for deluge system by routing air from a plant air hose out'et to the system drain or ball check valve. Once airflow is established airflow can be verified at the nozzles. The test prescribes three methods that can be used to check for airflow. Each of these methods require the tester to physically access the spray nozzles. Through discussions with IRM personnel it was determined that a pinwheel on a stick was used in determining airflow, which was not specifically described in the procedure. The use of a pinwheel would be equivalent to the three methods listed in the procedure.

While performing the walkdown of the test identifying all of the sprinkler heads without knowing the total number of heads installed in the area or the use of a design print was extremely difficult. To ensure accurate performance of the test specific guidance on identifying the heads should be given to the performer.

The description of alarms received on local panels and control room panels did not provide coordinate locations that would provide venfication that the proper alarm window or panel light has activated. In the case of alarms on release control panel it could not be determined which light the test performer would expect to light during the test. A-C-1 APP.2 EXH.11 should be referenced for describing information in surveillance tests.

Conclusion - ST-7-022-730-1 (FSWS Air / Water Nozzle Flow Test) if performed as written will not dump the system. Plant impact statements should be included in the test to wam shift supery!sion of the change in status of the system and ensure that compensatory actions are naintained.

Concern #4 - Penetration seat surveillance test references incorrect drawings.

Review Results - Reviewed ST-7-022-922-2 rev. 5 attachment #1 " Penetration Inspection Data Sheet" requires a listing of penetration seal detail drawing numbers. Based upon review of the ST completed 2/27/96, seal area drawings were referenced instead of seal detail drawing numbers. The surveillance test contains inspection criteria to verify that damage has not occurred to the penetration seal. Concern was noted that if the seal ,

installation detail is not reviewed by the test performer critical design parameters may be i missing from the installation. The seal inspection test should ensure that degradation to the ps.ietration seals have not occurred and that the visible seal parameters meet the .

tested configuration.

Conclusion - The penetration seal inspection procedure was performed as written in February 1996. In our opinion the test performed meets the intent of the Technical Requirement Manual (TRM). The test did not provide clear direction to use installation design details. The test does provide acceptance criteria that will identify physical damage to the penetration seals. We believe the test can be improved by ensuring that the test performer completely understands the visual parameters that are important to ensure the seat is bounded by a fire test. While addressing this issue SECY 06-146 should be referenced.

Concern #5 - Emergency Lighting - A procedure was not developed to direct lights toward emergency equipment.

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, Rev'ew Results - RT-6-108-300-2 rev.3, RT-6-022-108-300-0 rev. 4 and RT-6-108-300-1 rev.4 (Safe Shutdown Eight (8) Hour Self-Contained Battery Pack Operation Verification) all require the performer to verify that ernergency lighting is directed towards required equipment for safe shutdown and access pathways. A walkdown was performed using RT-6-108-300-2 which was last performed by operations on July 30,1996. During the walkdown the aiming of 24 emergency lighting units were evaluated. All lights were observed to be aimed in the area of the equipment identified in the procedure. When trying to assess the lighting in stair-towers and some general area lighting the test did not provide enough direction to accurately determine the proper aiming. This issue was discussed with IRM personnel who were aware of the need to better identify the appendix R lighting and produced an AT AITL type NR A01034738 written in June of this year requesting engineering to identify the require safe shutdown lighting. The response to the NR indicates that a revision to the test procedures and possibly plant drawings will be required.

Conclusion - In our opinion, procedural guidance is in place to require verification that emergency lighting is directed towards appendix R safe shutdown pathways and equipment.

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